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1、Enabling circularity Enabling circularity through transparency:through transparency:Introducing the EU Digital Product PassportJanuary 20231 1Focus of this publicationThree DPP publications with different purposesThree DPP publications with different purposesInforms about DPP and shapes regulatory d

2、iscussions incl.corporate engagementPrepares companies and motivates to participate in regulatory discussionsInforms all readers and combines all publicationsEnabling circularity through transparency:Introducing the EU Digital Product PassportNavigating uncertainties of the EU Digital Product Passpo

3、rt:How to prepare now as a companyThe EU Digital Product Passport shapes the future of value chains:What it isand how to prepare Introduces EU DPP and objectives Summarizes EU DPP status as of December 2022 Outlines options for open policy elements and discusses implications Summarizes regulatory st

4、atus Illustrates key implications along electronics value chain Highlights actions companies and the EC can take to prepare for the DPP Introduces EU DPP from a corporate lens Outlines why companies should act now and how they can prepare Highlights challenges and additional growth opportunitiesCONT

5、ENTPURPOSECONTENTPURPOSECONTENTPURPOSE2 2Executive summaryIntroductionEU DPP analysisConclusionIntroduction A digital product passport(DPP)is a structured collection of product related data across a products lifecycle to advance the transition to a circular economy and thereby support economic growt

6、h A few examples of DPPs exist,but the EU is the first regulatory mover at scale EC is currently drafting the DPP regulation.A first passport for industrial batteries has been drafted First product group expected to be affected by regulation in 2026/7.DPPs are expected to be mandatory for most indus

7、tries by 2030 EU DPP regulation is expected to impact global value chainsEU DPP analysis Many elements in EU DPP are still open with different levels of maturity,the same applies to the battery passport regulation Several topics remain unclear and are expected to be answered by the EC:SCOPE Product

8、groups:Which industries/product groups should be prioritized and why?Company size:Should requirements differ by company size?Application level:What level should DPPs be applied at?TECH Data storage:How and by whom should data be stored?Data carrier:What data carrier(s)should be used?Access/security:

9、How should access to the data be allowed?DATA Data requirements:What information/data will be included in the DPP at what degree of standardization?Governance:Who collects and updates the data?How is the DPP data verified?Conclusion The EU DPP is a first of its kind strong regulatory circularity too

10、l.However,many questions remain unclear and a long timeline to full implementation is expected In detailing the DPP regulation,abalanced approach between quickest and optimal options is relevant to enable companies to prepare for the DPP Despite the uncertainties and the long timeline,companies bene

11、fit from preparing for the DPP implementation nowMore details can be found in our separate publication:Navigating uncertainties of the EU Digital Product Passport:How to prepare now as a companyExecutive summaryExecutive summary3 3ContentContentIntroductionEU DPP AnalysisDataScopeTechConclusion41342

12、14352334 44Introduction5 5 5DPPs have several DPPs have several functionalitiesfunctionalitiesCollect product information across the product lifecycleDigitally store data(e.g.,in the cloud)Provide easy data access to stakeholders(e.g.,through scannable QR codes)(Re-)User/RepairerDistributorRaw mater

13、ial producerManufacturerBrand/DesignerCollector/Recycler/Refurbisher/Remanufacturer Origin of raw materials Recycled vs.virgin Resource consumption Deforestation Emissions Water/ground contamination Water usage Emissions Waste Water/ground contamination Transport.emissions Packaging(Eco-)labels Wast

14、e generation Product impact User manual Repair instructions Disposal instructions Disassembly instructions Recycling instructions Repair history1.Non-exhaustive;this graph has the purpose of illustrating what information a DPP could collect across a products lifecycle,final DPP information depends o

15、n further specification by the EC.Responsibility for data collection,DPP creation,etc.will be discussed later in this publication(see page 40)Source:BCG analysisThey share product information across They share product information across the product lifecyclethe product lifecycleExemplary information

16、 shared in a DPP across the product lifecycle1Executive summaryIntroductionEU DPP analysisConclusionExtract raw materialsRecycleDesignManu-factureDistri-buteUse/RepairCollect56 6 and thereby drive and thereby driveeconomic valueeconomic valueEmpowers informed,more environmentally conscious decision-

17、making across the value chain(VC)Creates corporate value through collaboration(e.g.,operational efficiency improvements and innovation of new materials/products,business models,and markets)Facilitates effective management of waste flows and EoL1treatment,thereby increasing recycling rates and access

18、 to recycled materials and productsLeads to higher value retention from waste,longer material lifetime,job creation,and lower raw material dependency,thus mitigating impacts of supply shocks and price volatilitiesEnables traceability of environmental impact and thus more accurate measurement(e.g.,sc

19、ope 3 emissions)Enables more efficient energy and resource consumption and thereby reduces associated costs for economy,society and env.Provides common foundation and clear requirements for becoming circularEnsures an equal level playing field,enhances visibility and credibility of sustainable produ

20、cts,and decreases VC deficienciesEnables setting and digitally tracking regulatory circular economy targets and verifying compliance with themSpurs digital capability development of authorities,thereby increasing the efficiency of regulatory processes and reducing resource spendingDPP could be a key

21、 tool to improve DPP could be a key tool to improve circularity circularity Executive summaryIntroductionEU DPP AnalysisConclusion1.EoL:End of life7 7Final approval of DPP regulation expected in 2023/4 with delegated act for first product group to come into force 2026/72;a first product passport has

22、 been drafted for batteries3DPP regulation expected to be drafted for majority of industries by 2030 with exception of 7 product categories(e.g.,food)4DPP regulation expected to have a global impact due to global nature of supply chains and as other regulators might follow the EU exampleScope:EU reg

23、ulation to also include eco-design&performance requirements DPP as tool to facilitate those and thus core focus of this publicationExecutive summaryIntroductionEU DPP analysisConclusion1.Based on analysis of 25 DPP examples 2.Most likely those highlighted in CEAP incl.electronics and ICT,batteries a

24、nd vehicles,textiles,plastics,construction and buildings;despite mentioned in CEAP,packaging is not expected to have a separate delegated act 3.The battery passport will come into effect for industrial and electrical vehicle batteries first from early 2027 4.Full list of categories excluded from DPP

25、 regulation:Food,feed,medicinal products,veterinary medicinal products,living plants,animals and micro-organisms,products of human origin,products of plants and animals relating directly to their future reproduction;Source:Company/initiative websites;European Commission,ESPR proposal,BCG analysisEC

26、proposes DPPs as first regulatory EC proposes DPPs as first regulatory mover at scalemover at scalebut DPP draft remains vague but DPP draft remains vague with slow timelinewith slow timelineFinal DPP format and content remain unclear at this pointSeveral examples exist(e.g.,Madaster,KEEP),but most

27、of them are early stage and industry-specific,with no regulatory examples or broader implementation1EC is the first large regulator aiming for mandatoryDPPs to promote the transition to a circular economy,provide new business opportunities and support consumersHowever,DPP implementation poses signif

28、icant challenges for EC to implement given little learnings to build on the broad intended cross-industry scope and the complexity of DPP set-up78 81.The chart illustrates relationships between key policies and initiatives but is not exhaustiveSource:European Commission,European Union,ESPR proposal,

29、BCG analysisEco-design for Sustainable Products Regulation(ESPR),which establishes a DPPEuropean Green DealECs 2020 industrial strategyCircular Economy Action Plan(CEAP)ESPR builds on several Union policiesReplaces Eco-design Directive,extending the scope and covering broader range of productsUpcomi

30、ng initiative on Green ClaimsProduct-specific legislation(e.g.,batteries,detergents,and toys)REACH rules that govern chemicalsMarket Surveillance RegulationEco-design DirectiveEmpowering Consumers in the Green transitionSustainable Corporate GovernanceEU Textile StrategyCircular ElectronicsESP measu

31、resIllustrative1Battery RegulationBattery DirectiveESPR takes targeted action to specific product/product value chain needs or problemsProduct-specific levelRefers to legislation for a specific product or a well-defined product groupHorizontal levelRelates to general rulesabout aspects across broadr

32、ange of productsESPR complements and concretely reinforces horizontal initiatives by specifying general rulesEcoEco-design for Sustainable Products Regulation(ESPR)establishes EU DPP design for Sustainable Products Regulation(ESPR)establishes EU DPP and is key link between policiesand is key link be

33、tween policiesExecutive SummaryIntroductionEU DPP analysisConclusion9 9European Commission plans first product group regulation European Commission plans first product group regulation to come into force in 2026/7to come into force in 2026/71.To rapporteurs,members of committee,any MEP or during pub

34、lic hearings 2.EC proposals can earliest be adopted after first reading by both EU Council and European Parliament 3.EC aims at reaching final approval latest before the 2024 European Parliament Elections 4.Packaging will not be regulated by a separate delegated act but covered as component of produ

35、cts across product groups 5.Initial ambition by EC were covering 3-4 delegated acts per year,but based on interview with the EC 2-3 acts seem more realistic;Source:European Commission,ESPR proposal,CEAP,BCG analysis20222023Adoption by European CommissionApril 22First reading2commenced in EU CouncilF

36、irst reading(no deadline)TBDFirst reading2in European Parliament2024Conciliation CommitteePossible to submit opinion on proposal1Additional readings2Final approval expected32023/42025DPP required for industrial&electricvehicle batteriesDPP mandatory on textiles sold in EUDrafting of 7-14 new delegat

37、ed acts5March 22TBDTBD202720302024-20272028-2030Drafting of 6-12 new delegated actsFirst reading(no deadline)Regulatory drafting by product groupPrioritized industries based on CEAPElectronics&ICT,batteries&vehicles,textiles,plastics,construction&buildings42030Executive SummaryIntroductionEU DPP ana

38、lysisConclusionDelegated acts per product group likely to be developed separately(even within industries),resulting in low alignment of acts and high complexity for companiesDPP to come into effect for initial product group(s)2026/71010DPP has global impact beyond EU bordersDPP has global impact bey

39、ond EU borders21,2,4,5,712116,7533,4Final assembly and testing inShenzhen,ChinaMetals imported,rare earth metalsmined in China1Accelerometer imported from GermanyScreen,flash memory from South KoreaNear field communications controller from the NetherlandsCamera,Compass,LCD screen imported from Japan

40、Wi-Fi chip,Audio Chips imported from USATypical supply chain for consumer electronicsEU DPP with global impact as regulation will be applied to imported products,its components and intermediary products the same way and at the same time as to domestic onesEU DPP may inspire additional regulation glo

41、bally thus potentially applying to even broader scope of companies and value chains in the future7654321Executive summaryIntroductionEU DPP analysisConclusion1.One country is specified as an example for each material/component,but the map shows more regions of materials/components originIllustrative

42、1111Many elements in EU DPP still open with different levels of maturity;Many elements in EU DPP still open with different levels of maturity;similar picture for battery regulationsimilar picture for battery regulation1.Product model 2.Bluetooth 3.Fully grey Harvey ball indicates a topic is fully un

43、defined,fully blue indicates a topic is fully definedSource:European Commission,ESPR proposal,Battery Regulation proposal,BCG analysisTechDataData storage4Data carrier5Access/security6Data requirements7Governance8How and by whom should data be stored and managed?What data carrier(s)should be used?Ho

44、w should access to the databe allowed?What information/data will be included in the DPP at what degree of standardization?Who collects and updates the data?How is the DPP data verified?Rules for accessing,sharing,managing,etc.of data are yet to be establishedQR code and/or physical smart labelLabels

45、 on packaging for too small devicesConsumers,independent operators,etc.Further details should be developedCarbon footprint,minimal recycled content of scarce raw materials,etc.Details about information,KPIs and measurements developed in next 2 yearsEcon.operator placing battery on marketNo informati

46、on on verification or validationProduct groups1Which industries/product groups should be prioritized and why?All types of batteries on the marketCategories are revised and updated to reflect developments in market and useCompany sizeScope2Should requirements differ bycompany size?Same requirements f

47、or all companiesApplication level3What level should DPPs be applied at?Every battery shall have a battery passportSome industries prioritized/excludedPrioritization of product groups and remaining industries unclearImplementation across company sizesDifferentiation&SME support unclearDPP level defin

48、ed per product groupPreferred application level unclearDPP storage to be company-managedRequirements for DPP storage unclearList of options tbd by product groupStandardization and format unclearDifferentiated access per VC actorDetails on data access levels unclearRequirements to be specified by pro

49、duct group in delegated actClear definitions of data points missing and standardization unclearEconomic operator placing product on EU mkt.to collect&update DPP dataData verification remains unclearDegree of maturity in EU DPP regulation3Degree of maturity in EU battery regulationKey questionsStatus

50、 of EU DPP regulationBattery passport regulationExecutive summaryIntroductionEU DPP analysisConclusionOpen topicsBattery regulation drafted as first product group act;likely to inform further regulatory development1212A range of options for EC to consider when mandating or recommending A range of op

51、tions for EC to consider when mandating or recommending solutions in upcoming policysolutions in upcoming policy1.Refers to data storage beyond a EU-managed DPP registry that will be established for compliance purposes;no judgement on speed of implementation of remaining data storage as company-mana

52、ged may take longer than EU-managed,whereas early movers likely to be quicker than EU 2.Regulatory and/or corporate implementationSource:European Commission,ESPR proposal,BCG analysisTechDataScopeFaster implementation2Current EC proposalExecutive summaryIntroductionEU DPP analysisConclusionOpen topi

53、csOption space Expected type of EC regulationAcross all companiesMandateMandateMandateRecommendRecommendMandateMandateMandateProduct groupsCompany sizeApplication levelProduct group by product groupItemIndustry by industryLarge corporations firstLargecorporations onlyBatchProduct modelData requireme

54、ntsStandardization of data requirementsNo assuranceSpecification per product groupCombinationLimited assuranceReasonable assuranceData storage1Data carrierAccess/securityEU-managedQR codeFull accessCompany-managedMinimum accessDifferentiated accessCentralizedDecentralizedBarcodeRFIDWatermarkNFCBluet

55、ooth tags45678321Governance12Option assessment in next chapterFaster implementation is important due to the urgency of increasing circularity and the positive cost impact for companieshowever a balance with other aspects is key(see next chapter)Clear guidance needed on what/who is in scope,which lev

56、el to measure at and how to treat imports.This is essential to be fully aligned across VCs.Different tech solutions can exist next to each other as long as min.requirements are met e.g.,DPP success does not require one prescribed data carrierMin.requirements need to be mandated for relevant aspects

57、of data topics to ensure impact of DPP additional data points/assurance could be voluntaryClear guidance needed on who obtains what data access131313EU DPP analysis14S ScopecopeExecutive summary IntroductionEU DPP analysisConclusionClick to navigate through this document DataTechScopeKey questionsOp

58、en topicsProduct groupsWhich industries/product groups should be prioritized and why?1Application levelWhat level should DPPs be applied at?3Company sizeShould requirements differ by company size?2How and by whom should data be stored?4Data storageWhat data carrier(s)should be used?5Data carrierHow

59、should access to the data be allowed?67What information/data will be included in the DPP at what degree of standardization?8Who provides and updates the data?How is the DPP data verified?Access/securityData requirementsGovernanceDegree of maturity in EU DPP regulationFully grey:Fully undefinedFully

60、blue:Fully defined141515Product groups|Product groups|DPPs implemented per product group DPPs implemented per product group with unclear approachwith unclear approach1.The EC defines product groups as a set of products that serve similar purposes and are similar in terms of use,or have similar funct

61、ional properties,and are similar in terms of consumer perception;how this definition will translate into the final breakdown of industries into product groups currently remains unclear 2.Fully grey Harvey ball indicates a topic is fully undefined,fully blue indicates a topic is fully definedSource:E

62、uropean Commission,ESPR proposal,Battery Regulation proposal,BCG analysisProduct by product groupProduct groups prioritized based on level of their environmental impact,regardless of the industry Industry by industryProduct groups within a prioritized industry(e.g.,electronics)covered first,followed

63、 by product groups in another industryExisting international approaches and EC regulations related to product standards to be taken in the account for harmonizationImplications for other productsThe EC will implement delegated acts per product group,rather than industry level,similar to battery draf

64、t,Multi-year drafting process likely per product groupProduct groups1Implications for companiesVarying DPP requirements for companies covering multiple product groupsHigh level of uncertainty about prioritization,implementation timeline and definition of product groupsCompanies in prioritized indust

65、ries can start preparations despite uncertaintiesCorporate involvement in regulatory discussions can help shape EC mandate in line with preferencesDegree of maturity in EU DPP regulation2Degree of maturity in EU battery reg.Categories and their prioritization are decidedEncompasses all batteries and

66、 accumulatorsLarger batteries(e.g.,industrial and electric vehicle ones)will have DPP,but implementation for smaller ones unclearRevisions and updates to followBattery passport regulationStandardizationOptionsWhat product groups exist?How do industries break down into them?Which product groups are p

67、rioritized and why?How long will it take to develop and implement delegated acts per product group?European Commission to prioritize product groupsNGOs(e.g.,WBCSD)to provide industry input and environmental implicationsTimeline expectations Product group prioritization until end of 2023;first regula

68、tion for products expected in 2026/7Expected type of regulationMandate for clear guidance on what is in scope and full value chain alignmentPriority industries defined;product group prioritization unclearDPP implementation per product group1(EC definition remains unclear,e.g.,laptops vs.handhelds)Pr

69、ioritized industries but no indication on how EC approaches DPP implementation within industriesEC statusKey actors Open questionsExecutive summary IntroductionEU DPP analysisConclusionNo EC proposal yet1616First prioritized industries are outlinedFirst prioritized industries are outlinedExecutive s

70、ummary IntroductionEU DPP analysisConclusion1.Based on industries prioritized in Circular Economy Action Plan 2.ECs impact assessment accompanying the ESPR proposal 3.Gwenole Cozigou,Director at the European Commissions internal market departmentSource:European Commission,ESPR proposalUnmentionedind

71、ustries A number of industries(e.g.,cosmetics)are not mentioned in the EC documents but nevertheless likely to be included in the DPP at a later stagePrioritized industries1Electronics&ICTBatteries&vehiclesTextilesPlasticsFurnitureConstruction and buildingsChemicals2Excluded from DPP regulationFood

72、and feedMedicinal products and veterinary medicinal productsLiving plantsAnimals and micro-organismsProducts of human originProducts of plants and animals relating directly to their future reproductionProduct groups1but product group prioritization remains undefinedBreakdown of industries into produ

73、ct groups remains unclearPrioritization of product groups to be finalized by EC by end of 2023Delegated acts per product group likely to be developed separately(even within industries)resulting in low alignment and high complexity for companiesDraft framework for priori-tizing product groups to be p

74、ublished by EC early 2023Packaging will not be regulated by a separate delegated act,but will be covered by regulation as component of a product placed on the market31717Going industry by industry allows for higher alignment and speed of Going industry by industry allows for higher alignment and spe

75、ed of regulatory developmentregulatory developmentExecutive summary IntroductionEU DPP analysisConclusionProduct groups1Advantages/DisadvantagesDescriptionKey considerationsSpeed of regulatory developmentImpact on companiesEnvironmental impactProduct by product groupProduct groups prioritized based

76、on level of their environmental impact,regardless of the industry Low speed,given the complexity of the regulatory drafting and differences between product groups,may take multiple years per group,especially if delegated acts are not aligned High when environmental impact is the main driver for prio

77、ritization;total impact may be offset by slower implementationCompanies active in several similar or different value chains cannot benefit from synergies of the implementation across product groups;potentially more costly due to larger timespans and low alignment among delegated actsHigh environment

78、al impact,but low regulatory speed and alignment leading to limited synergies for companiesIndustry by industryProduct groups within a prioritized industry(e.g.,electronics)covered first,followed by product groups in other industriesHigher speed since delegated acts for product groups within one ind

79、ustry will overlap and could be re-used leading to higher alignment and predictabilityPotentially lower but prioritizing industries by environmental impact and speed of implementation with potential positive impact on environmentBetter synergies for companies active in several product groups of one

80、industry;no significant time delays between delegated acts;less costlyFaster implementation and higher alignment leads to corporate synergies at potential risk of lower impact DisadvantageAdvantageCombinationSource:BCG analysisNo EC proposal yet1818Company size|Company size|EC plans to implement DPP

81、 regulation EC plans to implement DPP regulation across allacross all companiescompaniesDPP regulation likely to be applicable across all companies regardless of size due to no further specification by EC and stance taken in battery regulationImplications for other productsSMEs expected to be affect

82、ed by regulation at the same time as large corporationsCompany size2Implications for companiesImplementation across all companies raises question about how the value chain will cover costs and who will pay theseParticularly for SMEs,early preparation for DPP implementation is importantLeveraging the

83、 influence of industry associations for advising the EC on feasibility is key for SMEsCorporate involvement in regulatory discussion can shape how and when SMEs are covered in mandateDegree of maturity in EU DPP regulation1Degree of maturity in EU battery reg.Regulation applies to all companies rega

84、rdless of size Requirements are the same for all companiesAssistance provided to SMEs where necessary to reduce regulatory burdenBattery passport regulationStandardizationOptionsWill company size play a role in the DPP implementation?Should requirements differ by company size?How will implementation

85、 be facilitated for large corp.vs.SMEs?European Commission to define scope for companiesCompanies and industry associations can advise on practicality and feasibility of DPP,specifically for SMEsLimited company size angle on DPP implementation No specific details about whether EC plans different deg

86、rees of implementation depending on company sizeHigh-level measures to reduce regulatory burden for SMEsare outlinedEC statusKey actors Open questionsExecutive summary IntroductionEU DPP analysisConclusionImplementation for large corporations first,SMEs follow laterImplementation across all companie

87、sImplementation for large corporations only,SMEs excludedEC proposal1.Fully grey Harvey ball indicates a topic is fully undefined,fully blue indicates a topic is fully definedSource:European Commission,ESPR proposal,Battery Regulation proposal,BCG analysisTimeline expectations All companies of one p

88、roduct group expected to be covered by DPP regulation at the same timeExpected type of regulationMandate for clear guidance on who is in scope to align expectations1919Implementing DPP across all companies enables transparency Implementing DPP across all companies enables transparency across the ful

89、l value chainacross the full value chain1.Will depend on stakeholder role and impact in respective VCSource:BCG analysisExecutive Summary IntroductionEU DPP analysisConclusionCompany size2Transparency and traceabilityLarge corp.SMEsEnvironmental impact1Speed of regulatory developmentAdvantages/Disad

90、vantagesKey considerationsDPP regulation will apply to all companies regardless of sizeFull transparency and data availability at high complexity for SMEs,thus likelyrequiring additional support Implementation across all companiesHigher transparency and traceabilitycan be achieved across VCHigher da

91、ta availability and reportingefficiency as data can be obtainedfrom all VC actorsHighly complex and costly as procuring resources and developing new capabilities is requiredDPP regulation will apply to large companies first,SMEs follow laterImplementation for large corporations firstHigh initial inv

92、estments for setting up DPP infrastructure but opportunity to shape the level playing field firstShort-term avoidance of costs and learnings from large corp.but long-term investments neededPartial transparency and traceability at first,increases at later stageFast implementation traded off for the o

93、pportunity to bring full transparencyand impact of the DPP to the VC immediatelyHigh as full transparency and traceability enables circularity and cross-stakeholder collaborationDelayed environmental impact as DPP only covers larger VC actorsat first;might slow down the process of transitioning to a

94、 circular economyMedium due to effort required from EC if support for SMEs specified;all companies covered by DPP earlierMedium as drafting is quicker for large corp.only,but additional regulation likely required for SMEs later onDPP regulation will apply to large companies only,SMEs excludedImpleme

95、ntation for large corporations onlyHigher complexity and costs for large corp.due to need for additionalresources to collect/estimate dataLimited transparency and traceabilityas SME data is not collected fullyNo regulatory pressure but large corp.could make data provision a conditionfor doing busine

96、ssFast implementation and unclearenvironmental impact at the cost of pressure in the VC,and lowertransparency and traceabilityHigh due to quicker implementationbut low if SMEs are key to full DPP implementation across VC Lower complexity for EC as fewer more homogeneous stakeholders involved,but com

97、plexity shifted to large corpsImpact on companiesDisadvantageAdvantageCombinationDescriptionEC proposal2020Application level|Application level|EC does not specify one preferred EC does not specify one preferred application level for DPPsapplication level for DPPs1.Industrial,EV&light means of transp

98、ort batteries prioritized 2.Stands for Global Trade Item Number which can be used to identify types of products 3.Fully grey Harvey ball indicates a topic is fully undefined,fully blue indicates a topic is fully definedSource:European Commission,ESPR proposal,Battery Regulation proposal,BCG analysis

99、DPP level expected to be specified for each product group separately Degree of standardization possible across product groups within one industryImplications for other productsItem-level application of DPP as outlined in battery regulation not necessarily realistic for all other products(e.g.,chemic

100、als)Application level3Implications for companiesCompanies might need to prepare for implementing different DPP levels per product groupFor initial guidance,companies could look at the battery passport regulation for an item-level DPP as this could serve as a blueprint for future EC delegated actsCom

101、panies and industry associations could advise the EC on the practicality and feasibility of DPP levels for industries/product groupsDegree of maturity in EU DPP regulation3Degree of maturity in EU battery reg.Regulation stipulates unique passport per batteryEach individual battery1placed on the mark

102、et or put into service shall have a unique battery passportHowever,certain data points(e.g.,carbon footprint,%recovered materials)can be reported on batch levelBattery passport regulationStandardizationOptionsWhich level will the DPP be applied at?What needs to be considered when implementing the de

103、cision for a certain DPP level?European Commission to define application levelCorporates and industry associations can give guidance on practicality and feasibility of optionsEC plans to apply DPP at item,batch or model levelEC does not specify which level is preferable across product groups,but wil

104、l decide for each group separatelyThis will depend on the complexity of the VC,the size,nature or impacts of the respective productsEC statusKey actors Open questionsExecutive summary IntroductionEU DPP analysisConclusionBatchItems grouped together identified by unique batch number share DPPItemEach

105、 individual piece with unique identifier has a unique DPPProduct modelItems sharing e.g.,same GTIN2 share DPPNo EC proposal yetTimeline expectations No specification on timing of decision-making,likely in line with acts per product groupExpected type of regulationMandate for clear guidance on DPP le

106、vel required forVC alignment2121Decision on Decision on applicationapplicationlevellevel willwill impactimpact the the waywayDPPsDPPsworkworkacrossacross VCsVCsApplication level3Executive Summary IntroductionEU DPP analysisConclusionKey considerationsThe level at which the DPPwill be applied has sig

107、nificant implications on the number of DPPs generated,the granularity of data made available in the DPP and the potential for downstream traceability of productsThe application level can significantly increase the complexity of DPP implementation for companiesPRODUCT MODEL(e.g.,all Model XY1 laptops

108、)BATCH 2(e.g.,all XY1 laptops from plant B)BATCH 1(e.g.,all XY1 laptops from plant A)ITEM 1ITEM 2ITEM 3ITEM 4(e.g.,oneXY1 laptop)(e.g.,one XY1 laptop)(e.g.,one XY1 laptop)(e.g.,one XY1 laptop)One common identifier for all items of same model(e.g.,each model XY1 laptop carries same ID number)Data car

109、rier of each item links to same product info(e.g.,avg.microplastic release)Common identifier for all items of one batch(e.g.,each model XY1 laptop from plant A carries same ID)Data carriers of different batches link to different batch infoUnique identifier for each individual item(e.g.,each XY1 lapt

110、op)Data carriers of different items link to different item information(e.g.,repair history)Product modelBatchItem2222Low as data reported on model level is likely less accurate and no traceability possible,since models are typically produced over long time spans and could only be traced in batchesHi

111、gh as data is specific and directly linked to each individual item;technically each item could be tracked individually but downstream traceability limited in EoL processes1DPPs can be applied at the level of an item,batch or product modelDPPs can be applied at the level of an item,batch or product m

112、odel1.Industry-wide standardization could ensure consistent DPP implementation,reduce complexity and increase user-friendliness,but could limit environmental value if harmonized at batch/model level 2.EoL operators(e.g.,disassemblers,recyclers)process large amounts of waste bulk-or weight-based,so s

113、canning each individual item does not seem realistic in the short-run due to need for significant investments and process redesignsSource:BCG analysisExecutive Summary IntroductionEU DPP analysisConclusionApplication level3Item levelBatch levelProduct model levelEC plans to define application level

114、per product group1Impact on companiesTransparency and traceabilityDPP applies at item level An item can be an individual piece that has a unique identifierOffers high level of transparency at lower speed of regulatory development and high complexity for corporatesHigh complexity and costs as unique

115、identifiers need to be created per item and EoL operators would have to scan each individual itemDPP applies at batch level A batch includes a group of items that share a unique batch numberModerate complexity and costs as less DPPs need to be created and batch documentation widely existsMedium as d

116、ata is aggregated per batch and thus less specific;tracing possible as long as batch is not taken apart(e.g.,during upstream VC stages but not during use/EoL)Adds complexity at medium environmental value and transparencySpeed of regulatory developmentSlow due to high complexity and need to implement

117、 DPP for each individual item across industries/product groupsModerate speed as batch likely easier to define and implement due to prevalent practicesEnvironmental impactHigh as detailed data is available that creates higher transparency on material value and potential circularity of products(e.g.,i

118、tem repair history)Limited if environmental impact of products occurs downstream,but high if impact occurs upstream,due to transparency and data availabilityDPP applies at product model level Product model can be items that have the same GTINGreater synergies as one DPP created for all items of one

119、model which lowers complexity and costsUnlocks speed and synergies at cost of transparency,traceability and impactHigher speed as DPPs per model can be created and defined based on existing standards(e.g.,GTIN)Low,as impact can only be unlocked if largest env.impact comes from design stages incl.mat

120、erial sourcing,as limited tracking possible beyond thatKey considerationsDescriptionAdvantages/DisadvantagesDisadvantageAdvantageCombination23TechTechExecutive summary IntroductionEU DPP analysisConclusionDataTechScopeKey questionsOpen topicsProduct groupsWhich industries/product groups should be pr

121、ioritized and why?1Application levelWhat level should DPPs be applied at?3Company sizeShould requirements differ by company size?2How and by whom should data be stored?4Data storageWhat data carrier(s)should be used?5Data carrierHow should access to the data be allowed?67What information/data will b

122、e included in the DPP at what degree of standardization?8Who provides and updates the data?How is the DPP data verified?Access/securityData requirementsGovernanceDegree of maturity in EU DPP regulationFully grey:Fully undefinedFully blue:Fully definedClick to navigate through this document 2424DPP d

123、ata needs to be collected,stored and accessed by actors along the DPP data needs to be collected,stored and accessed by actors along the value chainvalue chainExecutive summary IntroductionEU DPP analysisConclusion1.Data storage refers to DPP data required beyond the information provided in the EU-m

124、anaged registry for compliance purposes.Thus,while unique IDs per product will be stored in the registry,additional product information incl.emissions and the like needs to be stored separately.Source:European Commission,ESPR proposal,BCG analysis Level of access to DPP data could e.g.,differ by VC

125、stakeholder groupDPP data made accessible through machine-readable data capture medium(e.g.,QR code)DPP data stored by EU or companies in databases(e.g.,cloud/blockchain)#Topic relation-click to see an overview of the topicsData access6Data storage1Data carrier45TECHClearly defined data points requi

126、red for each DPPEconomic operator placing good on the EU market legally required to update DPP dataData governance8Data collectionData verificationData requirements887DPP data verification required(through econ.operator or third party)DATAData update8Economic operator placing good on the EU market l

127、egally required to collect&provide required data2525Data storage|Data storage|EC proposes companyEC proposes company-managed solution managed solution for DPP data storagefor DPP data storage1.Final format of EU registry yet to be specified thus currently unclear whether data beyond unique IDs will

128、be collected in this registry.2.EC,Battery Regulation Proposal 2.Two sets of possible options are analyzed.Set 1 related to responsibility of platform set-up,ownership and mgmt.,set 2 related to options for storage technologies 3.Fully grey Harvey ball indicates a topic is fully undefined,fully blue

129、 indicates a topic is fully defined;Source:European Commission,ESPR proposal,Battery Regulation proposal,BCG analysisEC aims to have a standardized registry for all products,including at least a list of unique identifiers Beyond the registry,the EC is planning limited standardization with leaving da

130、ta storage to companiesImplications for other productsIt is yet unclear if the electronic exchange system will be standardized across product groups.It only applies to specific batteries within the battery product groupData storage 4Implications for companiesHigh uncertainty regarding DPP systems an

131、d associated costPotential issues with data security and safety in relation to IP protection,confidentiality,etc.Investments may be needed to set up and integrate DPP systems with existing systems(highly complicated if blockchain)Given EC is expected to recommend guidelines not to mandate a solution

132、,companies can start preparing nowDegree of maturity in EU DPP regulation4Degree of maturity in EU battery reg.Battery DPP info will be stored in an EU-owned systemEC plans to set up the electronic exchange system for rechargeable industrial and electric vehicle batteriesFuture acts will establish s

133、ystems architecture&“rules for accessing,sharing,managing,exploring,publishing”2Battery passport regulationStandardizationOptions3Who will set up,own and manage the platform for DPP data?How will responsibilities be divided?What technologies shall be used for data storage?European Union to decide DP

134、P systems and implementationSpecialized IT service providersCorporates&NGOs(e.g.,WBCSD)can provide inputsEC plans to set up a registry,but leave storage to companiesEC plans to set up and maintain a standardized DPP registry to store a list of unique identifiers at the minimum1Remaining DPP data to

135、be stored by companies with no specification of preferred data storage yetEC statusKey actors Open questionsExecutive summary IntroductionEU DPP analysisConclusionEU-managed platform for DPP dataCompany-managed solutions for DPP data Centralized storage(e.g.,on cloud or on-premise)Decentralized stor

136、age on multiple computers(e.g.,blockchain)12EC proposalNo EC proposal yetTimeline expectations Design and testing of the registry throughout 2025 and implementation in 2026Expected type of regulationRecommendation incl.a list of storage option(s)with defined min.requirements122626CompanyCompany-mana

137、ged solutions offer higher flexibility managed solutions offer higher flexibility but require clear EC guidance to ensure interoperabilitybut require clear EC guidance to ensure interoperabilityExecutive summary IntroductionEU DPP analysisConclusionData storage4EC proposalDisadvantageAdvantageCombin

138、ationEU-managed platformCompany-managed solutionsEU sets up,owns and manages a unified platform for storing all DPP data,which companies provide and access data throughCompanies determine themselves how to store and manage DPP data,following ECs overarching guidance and principlesEase of implementat

139、ionAdvantages/Disadvantages1Key considerationsStandardization potentialCost forWould require a one-off administrative cost by the EU for setting it up and continuous investments in maintenanceAdopting company-managed solutions requires clear EC guidance(e.g.,based on a data exchange protocol2)to avo

140、id development of multiple competing,costly and incompatible solutionsNo cost for the EU,but(financial)might will be needed,especially for SMEs Although potential to leverage existing IT systems,there is high risk of creating multiple different solutions within value chains and product groups leadin

141、g to significant complexity(for e.g.,EoL operators needing to access multiple platforms)Relatively easy to implement across product groups and VCs due to standardized platform across product groups,but companies will need to change their IT setup to ensure interoperability with EU platformVC accessi

142、bility Easy to standardize across different product groups,industries and value chains but potential limits to adopting solution to product group,VC or industry needsDifficult to standardize,as companies can choose different options;standardization only possible through voluntary collaboration acros

143、s the VCs,product groups and industriesA unified platform may take time to create and result in an inefficient system if not co-designed with companies to enable interoperability and automationNo cost for the setup,but investment will be needed for aligning and integrating existing IT infrastructure

144、 with the EU platformCompanies will have to invest;cost will vary depending on the chosen solution,collaboration with other stake-holders to create a system or usage of third-party platformsLarge number of potential solutions requires suppliers and EoL operators to access multiple portals in order t

145、o utilize and provide DPP data,significantly increasing complexityCollecting all DPP data in one designated EU platform allows easy access for all VC stakeholders(once sufficient IT infrastructure is in place)the EUcompaniesDescription1.Speed of regulatory development and environmental impact not an

146、alyzed here,as they are likely to differ only slightly between both options 2.For an example of a data exchange protocol please refer to the WBCSD-hosted Partnership for Carbon Transparency(PACT)Source:BCG analysis2727Regardless of who manages the solution,cloud and blockchain could Regardless of wh

147、o manages the solution,cloud and blockchain could be used for DPP data storagebe used for DPP data storageExecutive summary IntroductionEU DPP AnalysisConclusionData storage41.Additional studies are required to assess the environmental impact of the blockchain technology Source:BCG analysisBlockchai

148、nCentralized system all data is stored on servers in-house or on cloud Decentralized system the data is stored on multiple computers(or nodes)connected through a decentralized storage network On-premises On cloudMore costly to maintain but more control over dataData security at riskCost savings 30-5

149、0%Data security improved due to frequent tech updatesData loss potentialBlockchain is an energy-intensive technology and energy consumption could increase exponentially if used for many products across multiple VCs,potentially impacting environment adversely in sum1Given the similarity between cloud

150、 and on-premises as well as shift towards storage on cloud by enterprises,only cloud compared with blockchain in the followingGiven the high energy consumption of storing large data sets,green clouds and data centers should be considered to increase the sustainabilityCloud and Blockchain are not exa

151、ctly mutually exclusive options and could be used in combination when the clear goals of the solutions are defined.The crucial difference is in the availability of Blockchain protocols,i.e.,rules that define interactions,maintain security and cannot be overwritten in the network.2828Cloud offers sig

152、nificant benefits due to ease of implementation Cloud offers significant benefits due to ease of implementation and low costand low costExecutive summary IntroductionEU DPP analysisConclusionData storage4No EC proposal yetDisadvantageAdvantageCombinationCloud solutions1BlockchainEase&speed of implem

153、entation Permissioned accessAdvantages/Disadvantages2Key considerationsTransparency and traceability Data security CostCentralized data storage on remote storage systemsLower cost as solutions are widely adopted and utilized by companies/regulators alreadyHigher risk of a data breach and network fai

154、lure Easier and faster as already widely used;requires some alignment between different actors to ensure interoperability;could easily be standardized across industries;but limited automation capabilitiesLower price and wider adoption of cloud solutions can speed up DPP implementation,however,requir

155、es governance of data security and transparency to mitigate risksMore difficult to ensure high levels of transparency and traceability;governance requiredPossible to create different permission levels for different stakeholdersAlthough blockchain offers transparency and data security benefits,cost a

156、nd complexity of implementation likely to outweigh them,making it a less realistic solution for DPPsDecentralized data storage across products life cycle with consistent record shared in real time across all participants Data cannot be altered;low chance of network failureHigh implementation costs a

157、nd expensive tracking at an individual product level(e.g.,portable charger)Not used by companies at scale;integration with existingtech is unclear;all actors in one VC would need to agree to use one blockchain;different tech maturity across VC slows down adoption and increases potential resistance;b

158、utpossibility to automate processes and eliminate errors Guaranteed transparency and traceability as data cannot be changed once added;real-time visibilityAbility to maintain privacy where needed and control by whom,when and how data can be accessed Description1.Similar advantages apply for on-premi

159、se data storage(see page 27)2.Speed of regulatory development not analyzed here,as it is likely to differ only slightly between both options Source:The Energy Consumption of Blockchain Technology:Beyond Myth(2020),Sedlmeir,Buhl,Fridgen,et al.;BCG analysisEnvironmental impactCurrently lower energy co

160、nsumption per transaction than blockchain,but overall impact depends on implementationCurrently higher energy consumption per transaction,but full impact depends on implementation2929Data carrier|Data carrier|EC plans to specify data carrier(s)per EC plans to specify data carrier(s)per product group

161、product group1.Standards on Information technology,Automatic identification and data capture techniques,Unique identification 2.Defines the requirements for a QR Code 3.Accessibility requirements for products and services 4.Fully grey Harvey ball indicates a topic is fully undefined,fully blue indic

162、ates a topic is fully defined;Source:European Commission,ESPR proposal,Battery Regulation proposal,BCG analysisEC will likely aim for some degree of standardization to limit number of accepted data carriersImplications for other productsSame identifier(s)could similarly be adopted for other product

163、groupsExceptions will be in place for very small productsData carrier5Implications for companiesImplementation is currently unclear as highly dependent on list of carriers per product groupLack of clarity on how new carriers will be combinedwith/differentiated from current labelsPotential to impact

164、EC recommendation by setting industry standards or engaging in regulatory discussionsDegree of maturity in EU DPP regulation4Degree of maturity in EU battery reg.Battery regulation suggests use of QR codesThe QR code will be printed or engraved on all batteries,providing access to a batterys passpor

165、tIt should respect the guidelines of ISO IEC Standard 180042and Directive(EU)2019/88233Battery passport regulationStandardizationOptionsWhat data carrier(s)shouldbe used?Will it be the same for allproduct groups?How will smaller productsbe identified?European Union to propose data carrier(s)Corporat

166、es&NGOs(e.g.,WBCSD)can provide inputsISOto provide guidance on standardizationGeneral guidance on data carrier List of data carriers will be specified per product groupWill be released in accordance with international standards Shall comply with the ISO/IEC standard 15459:20151EC statusKey actors Op

167、en questionsExecutive summary IntroductionEU DPP analysisConclusionQR codeNFC tags and Bluetooth tags have not been mentioned in the EC regulation but show a lot of potential in a number of industries in the futureBarcodeRFIDWatermarkNFCBluetoothtagTimeline expectations No specified timeline,likely

168、inaccordance with delegated acts per product groupExpected type of regulationRecommendation incl.list of carrier options with defined min.requirementsNo EC proposal yet3030DescriptionQR code offers benefits but is not the single best optionQR code offers benefits but is not the single best optionDat

169、a carrier5Ease&speed of implementationA machine-readable matrix code that links to informationCurrently seems to be the most effective option on the marketQR codeMainly used as trigger to a webpage but able to provideinfo on condition of the productSlightly higher cost than of a barcode,but among mo

170、st affordable and effective options on the marketEasy and quick to implement,already used by many playersA machine-readable code in the form of numbers and a pattern ofparallel linesRFIDLess durable and lower data storage than other options but widely used across many VCsUser-friendlinessCan be easi

171、ly scanned by smartphones.Widely used by customers alreadyData storage featureCan sustain up to 30%of structural damage and still continue to functionImperceptible codes,the size of a postage stampDigital watermarkAdvantages/DisadvantagesKey considerationsBarcodeA wireless communication system compr

172、ised of tags and readersCan bring a lot of value for the whole VC but ease of access needs to be solvedDurabilityAble to tell only a products numberMost affordable optionEasy and quick to implement,already present on most productsCan be easily scanned by smartphonesHighly depends on the label materi

173、al and print qualityTags can store up to 128 kilo-bytes at increasing prices the more data is stored enough to store basic DPP dataThe typical tag is not expensive but has to be implemented together with scanners/readers,which increases the costHarder and slower to implement across the VC due to the

174、 reader tech,mostly used in warehousesOnly a couple of mobile phones can scan the tag,special scanner is neededUnder normal conditions,most tags can function for 20 years or moreAble to carry wide range of attri-butes(e.g.,manufacturer,SKU,type of plastics used&compo-sition for multilayer objects)Co

175、st may vary,shows a lotof potential for low value productsModerately easy&quick to im-plement,less widely used;useful for sorting of low value itemsA high-resolution camera is needed during sorting.Unclear how consumers can access dataDepends on the surface it is applied to,but details remain unclea

176、rCan store much data,but durability and cost remains unclear CostOptions mentionedbytheECExecutive summaryIntroductionEU DPP analysisConclusionDisadvantageAdvantageCombinationNo EC proposal yetSource:BCG analysis3131Although not mentioned by the EC,NFC and Although not mentioned by the EC,NFC and Bl

177、uetooth tags could have potentialBluetooth tags could have potentialData carrier5Additional optionsto consider,not mentionedbytheECNFCBluetooth tagsA sticker with small microchips and antenna that can be read by mobile devicesPotentially easier to use than other tag but limited to small distances;so

178、 far has been widely adopted for paymentsMicrocomputers the size of a postage stamp that power themselves by harvesting radio waves from nearby deviceProvides value for all stakeholders across value chain.Works best when combined with AI in the cloud and machine learningHas a lifespan of over 10 yea

179、rsSome tags last 4 years.Battery-free options may last longer but still unclearEvery tag has a memory chip.Amount of info stored depends on the tag type,ranges from 48 bytes to 1 megabyte.Most commonly used as a trigger to a websiteDo not store data.When there is no energy nearby,they will not trans

180、mit data.Highly dependent on the data transmission to the cloudEasy and quick to implement given their small size on a range of different productsHarder and slower to implement due to their novelty,at the moment only works paired with cloud solutionsRather expensive at about twice the price of an RF

181、ID tag,but does not require extra reading equipmentThe most expensive solution among all presented data carriers,but might get more affordable in the futureAdvantages/DisadvantagesCan be read by most smartphones.A user needs to bring in their phone within the range of 0.1 m and will be presented wit

182、h dataCaptures data within 10 m range,can be read via any existing Bluetooth devicesEase&speed of implementationUser-friendlinessData storage featureDurabilityCostExecutive summaryIntroductionEU DPP analysisConclusionKey considerationsDescriptionDisadvantageAdvantageCombinationNo EC proposal yetSour

183、ce:BCG analysis3232Data access|Data access|Will differ by stakeholder group with Will differ by stakeholder group with details yet to be specifieddetails yet to be specified1.Fully grey Harvey ball indicates a topic is fully undefined,fully blue indicates a topic is fully definedSource:European Comm

184、ission,ESPR proposal,Battery Regulation proposal,BCG analysisEC plans to specify access rights at product group level,thus,limited standardization across product groups/industries and potentially VCsImplications for other productsProduct group properties are likely to be considered when providing ac

185、cessDifferent actors likely to have different levels of access Data access6Implications for companiesData access levels will have significant impact on data security,privacy and IP Data transparency across supply chain and can optimize how players along the VC collaborateEC plans restricted transpar

186、ency for customer,thus limited impact on demand expectedCorporate involvement in regulatory discussions can shape EC mandate on access level per VC actorDegree of maturity in EU DPP regulation1Degree of maturity in EU battery reg.Differentiated access proposedKey data points to be publicly accessibl

187、e(incl.carbon footprint information,battery lifetime,etc.)Additional data points restrictively accessible to accredited economic operators,the EC or authoritiesBattery passport regulationStandardizationOptionsWhat stakeholder group should get access to what data?How are data security(e.g.,IP)and sta

188、keholder/user privacy ensured?European Union to draft regulation for data accessNGOs&consultancies(e.g.,WBCSD)can provide insights on what data is required by what stakeholderData access to be differentiated by VC stakeholder groupDifferent access levels per stakeholder group(e.g.,customers,manufact

189、urers,governments,etc.)Still unclear which group should have access/no access to what data and how privacy is ensuredEC statusKey actors Open questionsExecutive summary IntroductionEU DPP analysisConclusionFull access for all stakeholdersMinimum access(strictly on a need basis e.g.,limited access fo

190、r end users)Differentiated access based on stakeholder needsEC proposalTimeline expectations Timeline unclear,but likely in line with data requirements by product group actExpected type of regulationMandate for clear guidance on which actor has access to what data3333Differentiated access allows to

191、ensure data and IP protection Differentiated access allows to ensure data and IP protection while ensuring DPP impactwhile ensuring DPP impactData access6Allows full data access of information stored in DPPs to all stakeholders along the entire VCFull accessRisks for companies from loss of IP and po

192、tential revenue implications through increased transparency if high environmental impactSpeeds up implementation by requiring less regulation as access level is the same across VCAllows restricted access to minimum data needed to exclusively increase circularity(e.g.,low/no transparency for users)Mi

193、nimum accessSlows down implementation as EC needs to specify data needs and access levels per product groupHighest degree of IP protection and low revenue implications from limited customer transparencyFull access could pose risk to security of sensitive data(e.g.,IP protection,end user privacy,etc.

194、)Allows to protect data by makingthe minimum required data points available to each stakeholderHigh environmental impact fromfull transparency across valuechain enabling VC collaborationand circularityLower environmental impact,due to missing customer transparency and limited ability to promote circ

195、ularity across the value chainGrants differentiated levels of access to each stakeholder group based on their needs and decisions they need to makeDifferentiated accessAllows for IP protection,but potential implications on revenues from market tendencies towards less environmentally impactful produc

196、tsModerate speed of implementation due to differentiated access which can likely be standardized across product groupsHigh environmental impact at risk of data protection and securityHigh levels of data security at the cost of environmental impactEnsures protection of sensitive data while unlocking

197、environmental impactProtects highly sensitive information and associated security risk(e.g.,by aggregating data points)High environmental impact by enabling transparency across supply chain with lower degree of VC collaboration possibleAdvantages/DisadvantagesKey considerationsImpact on companiesEnv

198、ironmental impactData security/privacySpeed of regulatory developmentExecutive summaryIntroductionEU DPP analysisConclusionEC proposalDescriptionDisadvantageAdvantageCombinationSource:BCG analysisData aggregation currently not mentioned in ECs ESPRproposal but could be relevant to balance data secur

199、ity,transparency and readability of DPPs by combining multiple detailed data points into one aggregated data point3434Data needs differ by VC stakeholder and decisions Data needs differ by VC stakeholder and decisions they need to makethey need to makeData access6Source:Metabolic system data maps,BC

200、G analysisEoLUse/RepairManu-factureDistri-buteRetailersImporters/DistributorsEnd users/ReusersRepairersAuthoritiesManufacturersAssemblersRecyclers/Remanuf.CollectorsSTAKEHOLDERSDATA NEEDSDPP PURPOSEDECISIONS MADE(not exhaustive)Circular design Product design(incl.longevity,circularity,recyclability,

201、etc.)Use of materials,parts&packaging Choice of suppliersExtract raw mat.DesignRaw mat.producersBrandsProduct designersCompliance infoEnv.impact of raw materials,parts&componentsSustainable production Choice of energy source/consumption Decisions on water usage,emissions&waste management Factory pla

202、cementInfo on raw mat.,parts&componentsManufacturing infoTransparency Choice of transportation mode Choice of products Choice of packagingManufacturing infoProduct infoUse&repairProduct infoTransparencyMaterial circularity Choice of products Decision to repair/keep/update Decision(on how)to dispose/

203、whether to resell/recycleTransparency Actions on non-complianceMaterial circularity Decision on(degree of)disassembly Decision to remanuf.Degree of recycling vs.landfilling Up-vs.downcyclingDisassemblyRecyclingExecutive summaryIntroductionEU DPP analysisConclusionBCG analysis based on Metabolic syst

204、em data maps;not EC viewDecisions on raw material extraction/production practices required that will impact demand of raw materials but doesnot lead to specific data needs from other VC actors35DataDataExecutive summary IntroductionEU DPP analysisConclusionDataTechScopeKey questionsOpen topicsProduc

205、t groupsWhich industries/product groups should be prioritized and why?1Application levelWhat level should DPPs be applied at?3Company sizeShould requirements differ by company size?2How and by whom should data be stored?4Data storageWhat data carrier(s)should be used?5Data carrierHow should access t

206、o the data be allowed?67What information/data will be included in the DPP at what degree of standardization?8Who provides and updates the data?How is the DPP data verified?Access/securityData requirementsGovernanceDegree of maturity in EU DPP regulationFully grey:Fully undefinedFully blue:Fully defi

207、nedClick to navigate through this document 3636Data requirements|Data requirements|Overarching areas suggested,Overarching areas suggested,but details remain undefinedbut details remain undefined1.The EC defines product groups as a set of products that serve similar purposes and are similar in terms

208、 of use,or have similar functional properties,and are similar in terms of consumer perception;how this definition will translate into the final breakdown of industries into product groups currently remains unclear 3.European Committee for Standardization 4.Fully grey Harvey ball indicates a topic is

209、 fully undefined,fully blue indicates topic is fully defined;Source:European Commission,ESPR proposal,Battery Regulation proposal,BCG analysisEC plans for low degree of standardization Data points to be specified per product group rather than across product groups and industriesImplications for othe

210、r productsSimilar areas likely to be covered for other productsSpecifics and degree of standardization remain unclear7Implications for companiesLimited ability to foresee&prepare for data requirements,but ECmandate likely basedon existing EU requirements and global standards Unclear degree of standa

211、rdization acrossproducts could lead to high complexity,especially for companies producing across product groupsUncertainty of required data might add cost and reporting complexity as decisions made today might need to be revisedDegree of maturity in EU DPP regulation4Degree of maturity in EU battery

212、 reg.Initial topics suggested with specific definitions still lackingGeneral areas for data reporting proposedNo specific guidelines or definitions on what and how to reportBattery passport regulationStandardizationOptionsWhat data will be included in the DPP at what degree of standardization?How wi

213、ll the data need to be presented?European Union to define data requirements and degree of standardizationCIRPASS,UNECE2,CENCENELEC3,Corporates,NGOs(e.g.,WBCSD),etc.can provide inputs/recommendationsFirst data topics suggested without clear definitionsEC plans to implement different data points per p

214、roduct group1in specific delegated actsData topics outlined without specifications on data presentation and definitionEC statusKey actors Open questionsExecutive Summary IntroductionEU DPP AnalysisConclusionStandardizationData requirements largely the same across product groupsSpecificationData requ

215、irements set independently per product groupCombinationMost data require-ments standardized with product-specific additions/exemptionsEC proposalData requirementsTimeline expectations First regulated products with detailed data requirementsexpected by 2026/7Expected type of regulationMandate incl.a

216、list of min.required data points with voluntary additions3737EC proposes long list of relevant data EC proposes long list of relevant data topicstopicswithoutwithout providingprovidingclear data points or definitionsclear data points or definitionsData requirements7Durability and reliabilityEase of

217、repair,maintenance,upgrading,re-use,remanufacturing and refurbishmentEase and quality of recyclingAvoidance of technical solutions detrimental to reuse,upgrading,repair,etc.Use of substancesConsumption of energy,water&other resourcesUse or content of recycled materialsWeight and volume of the produc

218、t and its packaging(incl.product-to-packaging ratio)Incorporation of used componentsQuantity,characteristics&availability of consumables needed for use&maintenanceEnvironmental footprint along entire lifecycleMicroplastic releaseEmissions to air,water or soil Carbon footprintAmounts of waste generat

219、ed incl.packaging waste(and ease of re-use)&hazardous waste Conditions for useProposed data topics11.A separate list of complementary data points connected to technology/identification has been proposed by the EC(incl.unique product identifier,etc.)Source:European Commission,ESPR proposal,Battery Re

220、gulation proposal,BCG analysisExecutive Summary IntroductionEU DPP AnalysisConclusionNo clear definitions of data topicsNo detailed data points specified(even in EU battery passport)No ambition to standardize across product groupsLittle insights into data requirements for product groups beyond batte

221、riesLink to battery passportPerformance&durability parameters(incl.min.avg.duration,exp.lifetime)Total carbon footprint&intensity(kg&kg/kWh)Content&location of hazardous substancesConsumption of(electric)energyCollection of waste batteriesLevel of recycling,recycling efficiencies&recovered materials

222、Information regardingcomponents&materialsFor a more detailed overview of data points that may become relevant for the EU DPP,please reach out to a BCG contact listed on page 463838A mix of standardization and specification allows A mix of standardization and specification allows for impact and simpl

223、ified implementationfor impact and simplified implementation7Executive summaryIntroductionEU DPP analysisConclusionImpact on companiesThe data points required will largely be the same acrossall product groupsProcess advantages that risk environmental impact&transparencyAllows for preparation and lea

224、rnings across product groups,allows roll-out across multiple product groups at the same time thus reducing complexityDifferent data requirements will be detailed separately for each product groupLimited ability to prepare and is highly complex,especially for companies operating across product groups

225、,which may lead to inconsistencies within industries/VCs High impact from tailored regulation that complexify implementationEnvironmental impactEarlier implementation across large number of product groups,but standardized data points may be of limited relevance for specific productsImpact from tailo

226、red reporting on key material topics relevant for each specific product group,at a delay due to prolonged regulatory draftingSpeeds up process of drafting and updating regulation,but does not allow for tailored updatesSlows down drafting process,but allows for tailored updates perproduct groupA list

227、 of general data requirements will be standardized across product groups/industries with additions/exemptions per product groupAllows for preparation,but some complexity remains as companies need to report a number of specific data requirements per product groupBalance between process optimization a

228、nd environmental impactOptimized impact due to earlyimplementation paired with overarching relevance and tailored reportingSlows down drafting process,but allows for tailored updates per product groupSpeed of regulatory developmentData requirementsDescriptionStandardizationSpecificationCombinationDi

229、sadvantageAdvantageCombinationAdvantages/DisadvantagesKey considerationsEC proposalSource:BCG analysisTransparencyLimited transparency at high comparability of data pointsHigh transparency at limited comparability of data pointsHigh transparency and comparability of key data points3939EC can build d

230、efinitions on existing global EC can build definitions on existing global standardsstandardsExecutive summaryIntroductionEU DPP analysisConclusionGHG emissionsCorporate/VC/city levelLand-based emissionsCorporate level%recycled materialsCorporate levelWater use&contamination BiodiversityCorporate lev

231、el%material circularityCorporate/business unit/factory levelRecyclabilityProduct level(for plastics&packaging only)Non-exhaustiveData point defined1Standard/protocolLevel of definition7CTI V3.01.Examples,not recommendationsSource:Company websites,BCG analysisData requirementsWhat is missingWhat exis

232、tsDefinitions for all data points required in DPP or,where corporate-level definitions already exist,product-level definitions informed by existing globally acknowledged standardsEco-design requirements for specific product groups,industry-led DPP examples as well as reporting standards(e.g.,SBTI,CD

233、P)and guidelines(e.g.,EU guidelines on non-financial reporting)incl.some data point definitions at a corporate level4040Data governance|Data governance|Collection of data defined but Collection of data defined but verification remains unclearverification remains unclear1.The operator placing the pro

234、duct on the EU market is legally required to collect and provide DPP data and register the DPP,however,technically the DPP can be created earlier in the value chain to unlock synergies of data sharing and transparency 2.Fully grey Harvey ball indicates a topic is fully undefined,fully blue indicates

235、a topic is fully definedSource:European Commission,ESPR proposal,Battery Regulation proposal,BCG analysisNo assuranceself-regulatory implementation with spot checksHigh potential for standardization across product groups as validation of data quality is needed across product groups,industries and va

236、lue chainsImplications for other productsData collection and provision likely in line with battery passport thus responsibility of economic operatorData governance8Implications for companiesIn case of assurance companies likely to face higher costs and complexityAssurance will ensure verification an

237、d quality of DPP data thus enabling trust and collaboration across VCsAssurance more likely to be linked to data points with performance requirements in the futureEC mandate likely impacted by assessment of feasibility from companies and industry associationsDegree of maturity in EU DPP regulation2D

238、egree of maturity in EU battery reg.Economic operator responsible for data qualityNo information on verification or validationEconomic operator that places battery on the market ensures that the data included in the battery passport is accurate,complete and up-to-dateBattery passport regulationStand

239、ardizationOptionsHow is data verified?By whom is data verified(i.e.,third-party auditor or not)?European Union to provide guidance on data verificationSpecialized consultancies&auditors can provide insights on what level/cadence of data verification is realisticResponsibility for data collection out

240、lined,but no data verification considerations in current EC proposalEconomic operator placing product on EU market to collect and provide DPP data and register DPP in EU registry1Limited considerations on data verificationEC statusKey actors Open questionsExecutive summary IntroductionEU DPP analysi

241、sConclusionLimited assurancefor specific DPP data pointsReasonable assurancefor all DPP dataNo EC proposal yetTimeline expectations Unclear timeline,likely in line with delegated acts per product groupExpected type of regulationMandate for clear guidance to ensure data quality and availability4141As

242、surance enables data quality at cost and complexity for companies Assurance enables data quality at cost and complexity for companies 1.Likely not a feasible option in the long run and once the DPP is linked to performance requirements that companies will be held accountable toSource:BCG analysisDat

243、a governance8Self-regulated DPP implementation where economic actors are trusted to provide accurate dataAssurance of a number of key data points specified by the EC to ensure the data quality of thoseAssurance of all data providedby the economic actor to ensure data quality and validity of DPP data

244、DisadvantageAdvantageCombinationNo EC proposal yetImpact on companiesEnvironmental impactVC collaborationAdvantages/DisadvantagesKey considerationsEasy implementation for companies at risk of data quality,spot checks may counteract disadvantages in short-runTypically,low trust among VC actors thus l

245、imiting VC collaborationData quality issues likely to occur due to limited auditing abilities of companies(esp.SMEs)and potential tempering of dataNo additional cost and reduced complexity for companies,as no third party needs to be involvedEnsures high quality of key data points(important once DPP

246、linked to perfor-mance requirements);potential quality issues with remaining data pointsAdditional cost,lower speed of data provision and moderate complexity from involving third partyTrust in key data points will increase with VC collaboration to lesser degree than reasonable assuranceHigh quality

247、of key data points at moderate cost and complexity;unlocks environmental impactMedium,as no assurance-related regulation needed,but self-regulatory framework should be implementedMedium speed,as regulation for limited insurance and definition of data points requiredLikelihood of data quality issues

248、may limit transparency,product circularity and thus environmental impactUnlocks environmental impact by ensuring quality of key data points while minor quality issues may remainEnables high data quality across companies and VCs with low potential of data tempering(important once DPP linked to perfor

249、mance requirements)Enables high levels of trust among VC actors that will likely increase collaboration across VCHigh additional cost,low speed of data provision and increases complexity due to involving a third partyHigh data quality and environmental impact at increased cost and complexity for com

250、paniesLow speed,as detailed assurance regulation needed and significant support for companies requiredHigh data quality and accuracy ensures transparency and thus higher environmental impact from circularityData qualitySpeed of regulatory developmentExecutive summary IntroductionEU DPP analysisConcl

251、usionNo assurance1Limited assuranceReasonable assuranceDescription424242Conclusion4343In sum,EU DPP is a first of its kind regulatory circularity tool,In sum,EU DPP is a first of its kind regulatory circularity tool,yet with many open questions and long timelineyet with many open questions and long

252、timelineEU DPP is a strong tool to drive circularity and economic value through transparencyEU is a first mover on implementing a large-scale regulatory DPP requirementInitial elements outlined in overarching regulation and first product group examples existStrong interest from non-governmental play

253、ersEU DPP is on a good way to drive circularity Unclarity across many aspects makes actions for early corporate adopters more difficult as future requirements are not predictableInvolvement of companies and industry representatives will ease implementation and increase impactBuilding on existing sta

254、ndards and corporate practices is a key enabler but requires further clarification and fast(er)implementationExecutive summaryIntroductionEU DPP analysisConclusion4444In detailing DPP regulation a balance between optimal set-up and easier and quicker to implement alternatives is important for the EC

255、 to considerIllustrative focusing on large companies first creates significant impact quicklyImplementation for all companies brings benefits(e.g.,data availability)but batch or product level application might be sufficient for many VCs and faster to implementItem level application enables highest t

256、ransparency across VC but standardizing key data points allows for earlier implementation and lower complexityDefinition of data points per product group enables focus on respective highest impact topics but a shorter list facilitates and speeds up implementation and impact on those most crucial top

257、icsRequiring a long list of relevant data points maximizes transparency but collecting data and creating transparency are relevantstarting pointsSetting clear targets and performance requirements based on DPP data will drive impact but easier access to key data points enable transparency quicklyComp

258、lex system of restricted data access and aggregation of data drives business security and trust butExecutive summaryIntroductionEU DPP analysisConclusion4545Being an early adopter,even moving ahead of regulation creates corporate valueDespite uncertainties and given the ongoing regulatory process,a

259、range of actions are non regret moves,e.g.,Engage in shaping the regulation through direct engagement with the EC or collaboration across the VCAssess data availability and fill in the gapsEnable own organization to take the right decisions and optimize processes in light of the upcoming requirement

260、s,e.g.,ensuring synergies,engaging suppliers,Plan for changes in technology ensuring interoperability of IT systemsSee separate publication for more guidance for companies on how and why to act nowDespite Despite uncertainties uncertainties and long timeline,and long timeline,companies can companies

261、 can prepare for DPP prepare for DPP implementation implementation nownowExecutive summaryIntroductionEU DPP analysisConclusion4646Driving insights through collaborationThe WBCSD and BCG want to thank the authors and contributors involved in the creation of this publication for their extensive contr

262、ibutionsDiana SukailoConsultantMarie HoltorfAssociateFriederike EggertAssociateAuthorsMaayke Aime DamenDirector,Circular Economydamenwbcsd.orgLonne van DoorneAssociateJeff TurnerSenior AdvisorMerle Stepke-MllerProject Leader,Circular EAlexander Meyer zum FeldePartner&Associate Director,Global LeadCi

263、rcular EHolger RubelManaging Director&Sr.Partner,Sustainability&Circular EThis publication is the result of a collaboration by WBCSD stakeholders,BCG experts and external contributors.The intention of this set of publications is to educate about the upcoming EU DPP regulation,highlighting current un

264、certainties incl.what aspects can still be impacted and outlining key immediate actions for companies to prepare.A range of stakeholders was interviewed and reviewed drafts.Input and feedback from stakeholders listed above were incorporated in a balanced way.This does not mean,however,that every sta

265、keholder agrees with every view.This is the best knowledge as of December 2022 but changes to DPP topics can occur quickly.DisclaimerBeyond that,the WBCSD and BCG want to thank the contributors to this article,especially the WBCSD stakeholders,BCG experts as well as the external organizations involv

266、ed in this collaboration for contributing their time and knowledge.Contributors4747About the World Business Council for Sustainable Development(WBCSD)WBCSD is the premier global,CEO-led community of over 200 of the worlds leading sustainable businesses working collectively toaccelerate the system tr

267、ansformations needed for a net zero,nature positive,and more equitable future.We do this by engaging executives and sustainability leaders from business and elsewhere to share practical insights on the obstacles and opportunities we currently face in tackling the integrated climate,nature and inequa

268、lity sustainability challenge;by co-developing“how-to”CEO-guides from these insights;by providing science-based target guidance including standards and protocols;and by developing tools and platforms to help leading businesses in sustainability drive integrated actions to tackle climate,nature and i

269、nequality challenges across sectors and geographical regions.Our member companies come from all business sectors and all major economies,representing a combined revenue of more than USD$8.5 trillion and 19 million employees.Our global network of almost 70 national business councils gives our members

270、 unparalleled reach across the globe.Since 1995,WBCSD has been uniquely positioned to work with member companies along and across value chains to deliver impactful business solutions to the most challenging sustainability issues.Together,we are the leading voice of business for sustainability,united by our vision of a world in which 9+billion people are living well,within planetary boundaries,by mid-century.www.wbcsd.orgFollow us on Twitter and LinkedIn48Geneva,Amsterdam,Beijing,New Delhi,London,New York City,Singapore